Foreign Corrupt Practices Act in Russia

Compliance Strategies Given Russia’s Unique Cultural and Governmental Intricacies

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, July 16, 2008


Doing business in Russia means cutting through a lot of red tape. That red tape has paved the way for extensive bribery and corruption in Russia, thereby making it an FCPA minefield for U.S. businesses.

In recent years, the Securities Exchange Commission and the Department of Justice have increased scrutiny of U.S. companies' dealings with overseas officials and strengthening their FCPA anti-corruption enforcement efforts.

This heightened scrutiny makes it increasingly important for companies to have and implement a comprehensive FCPA compliance program tailored for each country in which they operate.

Listen as our authoritative panel of attorneys with FCPA and Russian experience discusses the risks of doing business in Russia that may trigger FCPA violations, working with Russian governmental agencies, and best practices for mitigating the risk of FCPA violations.


  1. Risk factors of doing business in Russia
    1. Russian business culture/practices
    2. Defining a bribe
    3. Exposure to third party you may not control
    4. Reach of the FCPA in Russia
    5. Russia’s Counsel Against Corruption
  2. Working with the Russian government
    1. Obtaining government licenses, permits and certifications
    2. Transparency in public procurement transactions
    3. FCPA affirmative defense to prohibition of payment that was lawful under rules/regulations of the country
  3. Best practices for mitigating risk (how to compete effectively while complying with the FCPA)
    1. Monitoring
    2. Compliance program — anti-bribery and accounting provisions
    3. Internal controls
    4. Education/training adapted to local conditions
    5. Due diligence — all third parties
    6. Steps if misconduct is suspected


The panel reviewed these and other key questions: 

  • What are the risk factors that make companies conducting business in Russia vulnerable to possible FCPA violations?
  • What types of conduct have triggered SEC and DOJ investigations into potential FCPA violations?
  • What lessons can be learned from recent SEC and DOJ enforcement efforts affecting companies doing business in or with Russia?
  • What are the best practices for companies to utilize in developing anti-corruption compliance programs and due diligence efforts?


Randy Bregman, Partner
Salans, New York

He heads up the U.S. desk of Salans CIS practice and has focused on the CIS for over 30 years. He has significant experience in corporate and M&A matters and advises Russian and Western clients in a diverse range of industries. He has also supervised litigation and administrative disputes in Russia.

Thomas K. Sprange, Partner
Steptoe & Johnson, London, England

He has extensive FCPA investigation experience and has expertise in conducting internal investigations and audits. He is a member of the firm's International Dispute Resolution Group. He also conducts risk assessments for clients in the context of regulatory compliance, including international and local anti-corruption a money laundering legislation.

Kyle A. Wombolt, Partner
Goodwin Procter, Central, Hong Kong

He conducts regulatory and internal investigations involving matters related to federal securities laws and the FCPA. He advises on the propriety of transactions and disclosure under the FCPA. He conducts internal investigations in over 20 countries, including China, and counsels on corporate governance and internal control issues for compliance under the Sarbanes-Oxley Act and the FCPA.


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